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Grand Rapids Water Resource Recovery Facility, Former Incinerator Ash Lagoon (Grand Rapids, Kent County)

EGLE Site Lead: Kent Walters, WaltersK7@Michigan.gov or 616-278-4350. Webpage last updated October 12, 2021.

Background

The Grand Rapids Water Resource Recovery Facility (GRWRRF) located at 1300 Market Avenue SW, operated a lagoon from approximately the 1970s to the early 1990s.  It held ash from the incineration of sludges generated from on-site wastewater treatment processes.  The ash was transported via pipeline and discharged into the lagoon where the ash was collected and stored.  After GRWRRF discontinued use of the lagoon, the majority of the ash was removed and disposed of at an alternate facility.  GRWRRF approached EGLE's Water Resource Division (WRD) because they wanted to convert the former lagoon to a first-flush storm water retention pond.  EGLE informed GRWRRF that the former lagoon had never been properly closed.  Proper lagoon closure requires soil and groundwater investigations before allowing storm water to be discharged to the lagoon. 

EGLEs Industrial Pretreatment Program (IPP) PFAS Initiative identified GRWRRF as a site of concern due to several chrome plating facilities and other sources of PFAS discharging to the GRWRRF.  Since the IPP initiative, GRWRRF has been actively reducing PFAS sources to their wastewater treatment process.  The IPP PFAS initiative also determined that wastewater sludges may contain significant concentrations of PFAS.  Because GRWRRF's former lagoon was used primarily to store ash from incinerated wastewater sludges, PFAS impacts to groundwater are a concern.

The generalized groundwater flow direction is towards the Grand River, immediately north of the site.  The groundwater flow direction is impacted by the surface water elevation of the Grand River, causing groundwater flow directions to range from northwest to northeast.  The Grand River is the only surface water body potentially impacted by past site activities.  There are no residential wells that would be impacted by this site.

Grand Rapids Water Resource Recovery Former Incinerator Sludge Lagoon PFOA+PFOS Groundwater Results Map

Recent Accomplishments

  • On October 5, 2021, GRWRRF submitted a quarterly monitoring report with PFAS sampling results for 12 monitoring wells. Eight wells tested above groundwater clean-up criteria. The highest exceedances included PFOA at 19 ppt collected from monitoring well MW-3 and PFOS at 123 ppt at monitoring well MW-10s. All other regulated PFAS were below criteria. 

Next Steps

  • GRWRRF to sample additional groundwater monitoring wells to the East to better define PFAS impacts to groundwater.

Residential Well Testing/Alternate Water Information

  • There are no residential wells in this area.

Upcoming Community Engagement

  • None scheduled at this time.

Sampling Results Summary

This chart reflects data received after 8/3/2020. Data prior to 8/3/2020 is reflected in the timeline below.

This table was updated to include all seven PFAS criteria effective 12/21/2020.

Type of Sample

Date Sampled (or Range)

Number of Sample Results Received

Number of Samples above Criteria*

Groundwater Monitoring Wells

August 19, 2020 - August 2, 2021 33 22

* Residential well and groundwater monitoring well results are compared to EGLE Part 201 criteria for 7 PFAS compounds:  PFOS (16 ppt), PFOA (8 ppt), PFNA (6 ppt), PFHxS (51 ppt), PFHxA (400,000 ppt), PFBS (420 ppt), and HFPO-DA (370 ppt).

Sampling Notes

  • On August 3, 2020, new Part 201 Criteria went into effect.  Historical sampling data compared to Part 201 Criteria >70 is captured in the historical timeline below.
  • MW-1S, MW-1, MW-2S, MW-2, MW-3S, and MW-3 all exceeded Groundwater-Surface Water Interface Criteria, and exceeded the new Part 201 Criteria for PFOS, with the exception of MW-2S.

 

Historical Timeline

    • On June 29, 2017, GRWRRF provided EGLE with an investigative workplan to begin closure of the incinerator ash lagoon.
    • On August 28, 2017, EGLE provided GRWRRF approval of their investigative workplan after more detailed and complete information was included. 
    • On October 3, 2017, the GRWRRF conducted incremental sampling of the lagoon bottom soils to determine if the soils had been impacted from historic use.  The soils were analyzed for 16 different metals.
    • On November 11, 2017, GRWRRF provided the results from incremental sampling.  The results indicated that of the 16 metals tested, 12 were above non-residential soil clean-up criteria per Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.  One metal was above direct contact criteria.  EGLE informed the GRWRRF that further investigative work would be required to determine the depth of impacted soils and investigate any potential groundwater impacts.
    • On November 22, 2017, GRWRRF provided a workplan to further investigate impacts to soils and potential impacts to groundwater. 
    • On November 27, 2017, EGLE provided the GRWRRF with comments on the proposed workplan, requesting more detail and additional information in the workplan.
    • On February 20, 2018, the GRWRRF provided EGLE a revised workplan, including EGLE's recommendations.
    • On March 13, 2018, EGLE approved the workplan for additional investigative work at the lagoon. 
    • On April 18, 2018, the GRWRRF started field work, completing additional soil and groundwater investigative work.
    • On August 21, 2018, GRWRRF provided a report summarizing the results of additional soil and groundwater investigative work. The results indicated significant impacts existed approximately three feet below ground surface.  Initial groundwater investigative work indicated no impacts to groundwater.
    • On September 26, 2018, EGLE consulted with the Materials Management Division's (MMD) Remedial Advisory Team to determine the best way to move towards closure for the site.
    • On October 1, 2018, EGLE provided the GRWRRF with Remedial Advisory Team's comments and additional requests, as well as two different paths to closure for the lagoon.
    • On February 4, 2019, GRWRRF informed EGLE that they were going to proceed to remove impacted soils and install three additional shallow groundwater monitoring wells due to concerns from the Remedial Advisory Team.
    • On December 12, 2019, GRWRRF provided sampling results from the three new shallow groundwater monitoring wells installed downgradient of the lagoon.  The results indicated Groundwater-Surface water Interface exceedances for some metals at all three shallow wells. 
    • On January 6, 2020, EGLE met with GRWRRF to discuss the need for PFAS sampling around the former lagoon.
    • On January 20, 2020, Materials Testing Consultants (MTC), representing GRWRRF, sampled all eight groundwater monitoring wells on-site for PFAS.
    • On March 31, 2020, GRWRRF provided the report summarizing the PFAS sampling results to EGLE for review.  This report indicated that two downgradient groundwater monitoring wells were in exceedance of groundwater standards.   
    • On June 20, 2019, EGLE collected a surface water sample from the Grand River 0.3 miles downstream of Outfall 001 at this site.  The PFOS was 4.9 ppt and PFOA was 3 ppt, both of which are below water quality standards. 
    • On June 23, 2020, GRWRRF installed three new monitoring wells and sampled them for PFAS.  GRWRRF also resampled five existing monitoring wells for PFAS.
    • On August 5, 2020, EGLE received the sampling results from the June sampling event.  Two of the three new monitoring wells tested above Part 201 criteria. The highest PFOS was 141 ppt and the highest PFOA result was 15 ppt collected from monitoring well MW-6.
    • On August 19, 2020, GRWRRF installed three additional monitoring wells and two groundwater monitoring points. GRWRRF also collected 8 PFAS samples from existing groundwater monitoring wells.
    • On September 21, 2020, EGLE had a conference call with GRWRRF to discuss PFAS results, steps moving forward and asking for additional supplementary information about the site and historic operations.
    • On October 16, 2020, EGLE received the sampling results from the August sampling event.  The highest PFOS was 294 ppt and the highest PFOA result was 24 ppt collected from monitoring well MW-10S.
    • Historical Sampling Chart: Data is reflective of criteria prior to August 3, 2020,  PFOS and PFOA Only

      This chart reflects data received prior to August 3, 2020.

      Type of Sample

      Date Sampled (or Range)

      Number of Samples

      Number of Results Received

      Number of Non-Detects  Number Between Non-detect and Standard*  Number Greater Than or Equal to Standard 

      Groundwater

      January 21, 2020 8 8 2 4 2
       Cumulative   8 8 2 4 2

      *Groundwater results are compared to EGLE Part 201 Criteria of 70 ppt PFOS+PFOA.

    • On May 13, 2021, GRWRRF and EGLE met to discuss the potential impact dewatering wells capturing PFAS impacted groundwater have on the sites National Pollutant Discharge Elimination System permit. 
    • On June 1, 2021, GRWRRF submitted a quarterly monitoring report with PFAS sampling results for 11 monitoring wells. Seven wells tested above groundwater clean-up criteria.  The highest PFOA was 27 ppt collected from monitor well MW-10S, the highest PFOS was 218 ppt collected from monitor well MW-10S, the highest PFHxA was 13 ppt from monitor well MW-6, the highest PFHxS was 14 ppt from monitor well MW-02, the highest PFBS was 35 ppt from monitor well MW-09, the highest PFNA was 4 ppt from monitor well MW-10S